The Evolution of the Compliance Officer
I spoke at the International Compliance Association (ICA) open day on 16th February 2017 in London. I touched on how the role of the Compliance Officer has developed over the years and how this may affect the existing Compliance communities career progression as well as those interested in becoming a Compliance practitioner.
Having recruited within Compliance for over 5 years, I seen significant changes in the industry in that time alone - The FCA took over 50,000 consumer credit and debt firms through an authorisation process leaving a little over half trading, Solvency II remained around for longer than expected, conduct risk was introduced enhancing TCF and so forth, but I wonder how much it has changed since the FSA (at the time) was formed. One thing is for certain, the demand for good regulatory professionals continues to grow.
Whether you are interested in getting into your first compliance position, are an experience Compliance practitioner looking to further your career with a new role or perhaps are taking on a professional course that the ICA offer, I am hoping to impart some insight as to what employers look for / how you may want to target roles or even how industry agendas and directives can help you advance your career.
I have been fortunate enough to have spoken to a wide range of Compliance professionals in my time, both from a candidate and client perspective. All have different personalities and approaches to regulatory and business standards (the majority of the time I have found that this can depend on the sector) however, all have the same goal in mind, 'the customer' (hopefully) and keeping the company they work with trading compliantly.
We have all heard of the Compliance profession being called the 'business prevention unit' (I’m sure this still makes some of you shudder), but we know that it’s an old and out-dated term typically used by business development, sales or marketing departments trying to sell on a “cooling off period” or attempting to claim that they offer the best product in the market on a 40 ft billboard without having any real evidence. Of course, this where specialists in Compliance marketing / financial promotions departments get involved.
Recently, I met with a CFO who used this term to describe the Compliance profession. They said that, "it’s bit like drawing the short straw and having added responsibilities and it is an expensive resource for something we can do ourselves”.
This got me thinking, although they may have been saying this light heartedly, does the profession still have this stigma?
I have worked in companies and experienced first-hand that Compliance used to be a back-office function (I am sure most of you have experienced this for yourselves in your time); somewhere you may have found your colleagues being moved into from other business areas rather than making them redundant/ jobless.
On one hand, great! – Companies aren’t making redundancies. On the other, it raises the question whether regulatory requirements are truly being understood and metby everyone in the team. What makes me say that? Well...
From a recruitment perspective, (with respect) I am aiming this at a junior to mid-level, it’s important for us as recruiters to find professionals who choose to be in Compliance, not those who were pushed or may have had their hand forced – and likewise it’s important for companies to ensure that the right people are in these areas.
After all, the FCA expect suitable and robust policies and procedures to be embedded into business’, which spans from advising the business and boards of emerging regulation, identifying operational training needs and shaping the right culture. So, unless you truly understand and buy-in to Compliance from the start, getting the right message across, whilst building and maintaining trust within the business is easier said than done.
From my own observations and speaking to industry professionals, I have seen a positive change. I do believe that companies are taking regulatory requirements more seriously. For example, I have noticed a rise in companies hiring to increase team sizes and ‘Compliance heads’ having to replace any staff losses. Typically speaking, Compliance teams are not getting smaller.
These days we have Chief Compliance Officers / Compliance Directors sitting on boards and reporting into the Chief Exec, or at least reporting into decision makers and boards. So much so, that recruiting a credible Compliance leader is high on the agenda when companies want to expand into other markets or are a start-up themselves.
Going back to my meeting with the CFO, although their remark about “the business prevention unit” may have been a passing comment, they did eventually point out that managing and adhering to the FCA requirements is a full time job in itself, and actually, if they are to trade with customers, retail or institutional, they need to be showing that they value regulations enough to have a dedicated Compliance Officer on site.
Someone once said to me that, “a good Compliance department will always be there. They’ll have good systems and controls in place no matter what regulatory changes occur or even if there’s a human error”. But I still wonder if this may have been the case 15 years ago?
So I took the liberty of speaking to a number of experienced professionals who were around before the FSA/ FCA was formed, when Compliance didn’t necessarily have a voice.
It was down to a responsible “Compliance” officer trying to do the right thing and influencing their colleagues that you ought to be conducting business in a certain way because it was the right thing to do. For those that are aware or experienced the transition from OFT to FCA will know how much this has changed the consumer credit and debt sectors.
Thankfully nowadays, it’s very different. The FCA has positively impacted our industry by introducing the likes of TCF, which led to conduct risk, which got some companies thinking about the associated reputational risks to their business. All of which have influenced companies to roll these focus areas out internally and in turn has driven recruitment needs for industry specialists.
For example the industry needs specialists in; Financial Promotions, Data Protection and Records/ Information Management, Financial Crime. In fact, apart from that the latter, some of these have been flying under the radar until now, but with certain directives such as GDPR coming into force, it’s bringing these professionals into the focus, which we expect will drive salaries up.
Most recently, SMR and the SIMR has been in the spotlight. A number of Compliance leaders I have spoken to believe that mentalities are changing, which is making their job easier, or certainly giving Compliance a more welcomed presence and truly making the profession a “business partnering role” if it wasn’t already. I am generalising somewhat as this does already exist in some companies, but I think you get my point.
So how does all of this link recruitment?
We’ve already touched on certain directives shaping key areas that you may want to pursue. GDPR, 4MLD, marketing, SMR (for the more experienced readers of this article) and so forth, but ultimately it comes down to looking where you’ll be most needed and actually, doing what you enjoy which will play to your strengths and skills anyway. I have seen candidates shape very successful careers out of one compliance discipline such as Financial Promotions. Of course, I appreciate that everyone will have different paths, but the fundamentals remain the same.
In terms of qualifications,it doesn’t matter how experienced you are, recruiters and employers still look at professional qualifications, as well as how consistent your experience is.
Phil Ryan (CEO of the ICA) and I met up about a month ago, and it was interesting to hear him ask about the ICA’s reputation and whether it was even recognised in the industry. Which was a bit of a surprise to hear, as I’m not aware of many others that stand out, but more so because most of the Compliance profession I speak to know, have heard, or better still - have a qualification provided by the ICA.
I’m not trying to preach to the converted, but recruiters and prospective employers do look for relevant professional qualifications. Again, it goes back to my comment on having true Compliance professionals in your team.
One of the topics that often come up when I’m talking to a hiring manager is exactly this. “It’s not essential, but if they have a professional qualification then even better”. Subconsciously, seeing those three letters next to your name makes a difference. That’s just human nature.
Without wanting to reinvent the wheel, my advice to you is, attend regulatory events and meetings. It is so important to remain current and sharp with industry topics. Understand what your peers are doing and what their thoughts are. After all, they have to adhere to, and set the same standards you do. Make sure that you can evidence that you are looking at regulatory developments and news outside of work, an ICA qualification is the best way to do this.
The most respected Compliance leaders I know do this and have openly said that this is what they look for when they are hiring.
As a final thought, what you do doesn’t need to be business as usual all of the time, be innovative. Stand out for doing the simple things well. That, with the right approach to educating the company you work for about Compliance will make you stand out and will ultimately progress your career.
Feel free to get in touch if want to talk over any of the above or want a conversation regarding the market and thanks for taking the time to read my article.
Chris 0203 817 9757